Policy version: 05 March 2024.
Autum and Autum.life (‘our app and website’) is provided by The Autumn Project Limited (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our app and website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your ‘personal data’) in connection with your use of our app and website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (‘UK GDPR’), EU-US Data Privacy Framework and the UK-US Data Bridge.
Given the nature of our app and website being catered towards 50 to 70 year olds, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our app and website please let us know so that we can delete that data.
This privacy policy is divided into the following sections:
- What this policy applies to
- Personal data we collect about you
- How your personal data is collected
- How and why we use your personal data
- Marketing
- Who we share your personal data with
- How long your personal data will be kept
- Your rights
- Keeping your personal data secure
- How to complain
- Changes to this privacy policy
- How to contact us
What this policy applies to
This privacy policy relates to your use of our app and website only.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our app and website. We will collect and use the following personal data about you:
- Your name, address and contact information, including email address and telephone number and any relevant company details.
- Any delivery addresses specified for your order or consultation
- Information to check and verify your identity, eg date of birth
- Your gender if you choose to give this to us
- Your height and weight if you choose to give it to us
- Information about any medical or health conditions
- Details of your marital status
- Location data if you choose to give this to us
- Your billing information, transaction and payment card or other payment method information
- Bank account and payment details
- Details of any information, feedback or other matters you give to us by phone, email, post or via social media. For example, when you login to autum services such as the App using one of your social media accounts we will collect your username (or full name), address and your profile picture to ensure we can deliver the service you have requested access to.
- Your account details, such as username and login details
- Your activities on, and use of, our app and website
- Information about the services we provide to you
- Your contact history and purchase history
- Information about how you use our app and website
- Your responses to surveys, competitions and promotions
If you do not provide personal data we ask for where it is indicated to be ‘required’ at the point of collection, it will delay or prevent us from providing services to you.
It is noted that some of this information is of the sort referred to as ‘special category’ data. Special Category data is ‘personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation’. The processing of special category data is subject to restrictions and enhanced duties of care.’
Where the data processed by us is special category data (for example your health data), we will rely on the following additional bases for processing that data; namely that it is:
- for the purpose of carrying out our obligations and exercising our rights as referenced in our terms and conditions in respect of Autum.Life
- to protect your vital interests
- for the purposes of preventative or occupational medicine
- in order to process personal data which is manifestly made public by you;
- for establishing, exercising or defending a legal claim
- for archiving purposes in the public interest
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
- directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase services via our app and website, post material to our app and website and complete customer surveys or participate in competitions via our app and website, and;
- indirectly, such as your browsing activity while on our app and website.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
| Create and manage your account with us | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Providing services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | To comply with our legal and regulatory obligations |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: – to comply with our legal and regulatory obligations – in other cases, for our legitimate interests, i.e. to protect our business, interests and rights |
| Customise our app and website and its content to your particular preferences based on a record of your selected preferences or on your use of our app and website | Depending on the circumstances: – where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Retaining and evaluating information on your recent visits to our app and website and how you move around different sections of our app and website for analytics purposes to understand how people use our app and website so that we can make it more intuitive or to check our app and website are both working as intended | Depending on the circumstances: – where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices | Depending on the circumstances: – to comply with our legal and regulatory obligations – in other cases, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Statistical analysis to help us understand our customer base | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Updating and enhancing customer records | Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products |
| Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant. | To comply with our legal and regulatory obligations |
| Marketing our services to existing and former customers | For our legitimate interests, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information |
| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary |
Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
How and why we use your personal data – in more detail
More details about how we use your personal data and why are set out in the table below;
| Purpose | Processing operation | Lawful basis relied on under the UK GDPR | Relevant categories of personal data |
|---|---|---|---|
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices | Addressing and sending communications to you as required by data protection laws, – the UK GDPR or Data Protection Act 2018 | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | – your name, address and contact information, including email address and telephone number and company details – your account details (username) |
| Addressing and sending communications to you | Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) | – your name, address and contact information, including email address and telephone number [and company details] – your account details (username) | |
| Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above) | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | – your name, address and contact information, including email address and telephone number [and company details] – your account details (username) | |
| To allow to signin and interact with our website and App using your social media accounts. | Information from social networks or online accounts – information from any accounts that you share with us. | Legitimate interests – Processing is necessary to fulfil the service you requested. | – your name, address and contact information, including email address and telephone number – your account details (username) |
How and why we use your personal data – sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Notifications and service updates
When you register your profile on the autum App, we ask you to agree a number of mandatory fields so that we can use the personal data you shared with us to communicate service updates and notifications such as changes to Terms of Use, Privacy Policy and functional changes to the autum app (see above ‘How and why we use your personal data’). This type of communication is known as Legitimate Interest.
Marketing
We may from time to time send you additional information produced by our third-party sponsors. We will use your personal data to send you marketing updates (by email, telephone or post) about the autum services, provided you gave explicit consent when you registered.
Consent in this context is when you have provided us with a clear indication of freely given, specific and informed permission to process your information, for example, by ticking a consent box. By consenting via the “tick-box” on the creation of your account, you will receive this additional information.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at contact@autum.life
- using the ‘unsubscribe’ link in emails
- clicking on the Settings menu in your app and unsubscribing
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of registration with us and will not inhibit your future use of the website.
We will always treat your personal data with the utmost respect and never share it with other organisations outside of The Autumn Project Limited for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
- Business partners, suppliers and subcontractors who are necessary in order to offer the services provided by our websites, apps and other services.
- Analytics and search engine providers that assist us in the improvement and optimisation of our app and content journeys such as Google Analytics.
- Software providers we have contractual agreements with to provide us with communications, database infrastructure and customer support tools that require storage of your data.
- Autum staff or those contracted to work for us when it is needed to fulfil their role.
- Any services who you give us permission to share your personal data with.
- When we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of companies in Autumn Project Limited, Group companies, our customers, or others.
- Third parties we use to help deliver services for the app and website and any relevant goods relatable to the service provided you, e.g. payment service providers, warehouses and delivery companies.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We will ask for your explicit opt-in consent before we share your personal data with any company outside the Autumn Project Limited and Group companies for marketing purposes.
We or the third parties mentioned above may also share personal data with:
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
Who we share your personal data with – further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you stop using your account we will delete or anonymise your account data after seven years.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your personal data | The right to be provided with a copy of your personal data |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object to use | The right to object: – at any time to your personal data being used for direct marketing (including profiling) – in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by our app and website |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time
You may withdraw consents by contacting contact@autum.life Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself (e.g. your full name, address) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Data is stored securely within the British Isles and is subject to the UK General Data Protection Regulation (‘UK GDPR’). We use some third party softwares to ensure optimal delivery of services to our users. These third party providers include:
- Google Analytics – to monitor how the site and app and how users are interacting with them.
- Customer.io – to store user registration data and behavioural trends of how people interact with our content.
- Brevo – for transactional emails and notifications to keep users informed of updates to our app and services.
In each of these cases, data may be transferred or stored outside the United Kingdom, when this occurs all data is protected under the EU-US Data Privacy Framework and the UK-US Data Bridge.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with:
- the Information Commissioner in the UK.
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes, we will take steps to inform you, for example via by including a prominent link to a description of those changes on our app and website for a reasonable period or by other means, such as email.
Cookie Policy
Please read this cookie policy carefully as it contains important information on who we are and how we use cookies on our app and website. This policy should be read together with our Privacy Policy (as above) which sets out how and why we collect, store, use and share personal information generally, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.
Who we are
Our app and website are both operated by The Autumn Project Limited. We are in the business of extending the life expectancy of 50 to 70 year old’s. For more information, please see www.autum.life.
Our app and website
This cookie policy relates to your use of our app and website, Autum and www.autum.life.
Throughout our app and website we may link to other websites, apps or online sources owned and operated by certain trusted third parties. These other third party websites, apps and online sources may also use cookies or similar technologies in accordance with their own separate policies. For privacy information relating to these other third party websites, apps and online sources, please consult their policies as appropriate.
Cookies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our app and website. We use cookies on our app and website. These help us recognise you and your device and store some information about your preferences or past actions.
For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.
For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
Consent to use cookies and changing settings
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to enable you to put items in your shopping basket and use our check-out process).
You can withdraw any consent to the use of cookies or manage any other cookie preferences by clicking on the ‘Cookies’ icon at the bottom of our app and website www.autum.life and Autum. You can then explain how to adjust sliders or untick boxes as appropriate to the mechanism. It may be necessary to refresh the page for the updated settings to take effect.
Our use of cookies
The table below provides more information about the cookies we use and why:
| The cookies we use | Name | Purpose | Whether cookie is essential for us to provide you with a service that you have requested and whether we will seek your consent before we place the cookie |
| Universal Analytics (Google) | _ga, _gali, _gat, _gid | This is a web analytics service provided by Google Inc which uses cookies to show us how visitors found and explored our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (eg how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had This cookie collects personal information including: Name, address, contact details. The cookie has a maximum lifespan and will expire after 2 years. See the following https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage for how Google uses the cookies and the data generated by them for guidance on how Google uses these cookies and the data generated by them. |
No, will therefore request your consent before placing this cookie |
Third party access to the cookies
The cookies we use will only be accessed by us and those third parties named in the table above for the purposes referred to in this cookie policy. Those cookies will not be accessed by any other third party.
How to turn off all cookies and consequences of doing so
If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.
For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.
How to contact us
You can contact us by post, email, or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
| Our contact details | Our Data Protection Officer’s contact details |
| The Autumn Project Limited, 2 Chancery Lane, Wakefield, WF1 2SS contact@autum.life |
Martin Werth contact@autum.life |
Do you need extra help?
If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).
See our Terms and Conditions.
